FDA Food Packaging Requirements: What You Need to Know

What Are FDA Food Packaging Requirements?

The FDA regulates many aspects of the food supply chain, including how food products are packaged, labeled, and prepared. The FDA's food packaging requirements ensure that food does not become contaminated by its cardboard or plastic packaging, is safe for consumers to eat, and doesn't pose a health risk. This impacts packaging suppliers directly since this requirement regulates direct food additives and contact substances and ensures that food labels and packaging doesn't change the food's smell, taste, or composition. 

Although the FDA does not require testing for all of its requirements, typically testing or vendor assurances are permitted for its packaging regulations for food products. In order to be FDA compliant, the FDA requires tests to ensure that the packaging material is safe for use in contact with food.

Understanding FDA’s CFR Parts 170-199

The FDA's Code of Federal Regulations (CFR) Parts 170-199 are a set of rules and regulations that govern food products and drugs intended for human consumption. These parts focus on direct and indirect food additives, food additive petitions, and irradiation of food. These regulations are generally recognized as the holy grail of FDA regulations for food packaging suppliers.

The CFRs worth noting for food contact are found in Title 21 and include: 

Food Contact Substances and Indirect Food Contact Materials

Food contact substances are exactly what they sound like: materials that come into direct contact with food during processing, packaging, transport, or storage. These substances are generally recognized as coatings, adhesives, and the packaging materials themselves. Indirect food contact materials are substances that do not directly touch food, but may still transfer to the food through migration. Examples of indirect food additives include inks, adhesives, and processing equipment coatings.

Notifications and FDA Approval Process

Food packaging manufacturers that want FDA approval for a new food contact materials must comply with the complicated food contact notification process outlined by the FCN program. This process means manufacturers need to notify the FDA of their intent to use a new substance in food packaging. The steps of this notification process are as follows: safety assessment and testing, submission of notification, an FDA review period, and final authorization.